IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA

RODNEY WRIGHT,

Plaintiff,

No.

vs.

ISLAMIC CENTER OF SOUTH FLORIDA, INC.,

COUNCIL ON AMERICAN ISLAMIC RELATIONS,

CAIR-FLORIDA, INC.

Defendant

_________________________________/

AFFIDAVIT

I, Joe Kaufman, hereby declare and state as follows:

1. I have personal knowledge of the facts stated
in this affidavit.

2. I am a permanent resident of the state of Florida
and the graduate of a large well-known university.

3. I have been an investigative journalist for FrontPage
Magazine since 2003. Since 1998, I have served as
the Chairman of Americans Against Hate, a civil
rights organization and terrorism watchdog group.

4. Shortly after the Sep 11, 2001 attacks, I assisted
the FBI in an investigation that resulted in the
shutting down of a Hamas-related charity operating
out of Deerfield Beach, Florida.

5. In September of 2003, I was invited by Johnnie
Byrd, then Florida Speaker of the House, to give
expert testimony in front of law enforcement and
government representatives at a forum on terrorism
and homeland security.

6. This past year, I have been a guest speaker at
several conferences concerning the issue of terrorism,
including the 2007 Intelligence Summit and the 2006
American's Truth Forum Symposium. Since 2003, I
have also appeared several times as a counter-terrorism
expert on the Fox News Channel.

7. The Islamic Center of South Florida (ICOSF), also
known as the Pompano Masjid, was incorporated in January
of 1984. It is located at 507 NE 6th Street, in Pompano
Beach, Florida. (Exhibit
1)

9. Found on every page of the ICOSF website is a link
to Islamic Finder, a site that describes in which
instances and to what degree a husband is allowed
to beat his wife and discusses an impending war between
Muslims and "the Jews plus other non-Muslims
led by the Antichrist." (Exhibit 3a
and 3b)

10. On the previous ICOSF website, www.icsfl.org,
there were links contained within it to the Islamic
Society of North America (ISNA) and the Islamic Circle
of North America (ICNA), two umbrella organizations
for radical mosques founded by members of the violent
Muslim Brotherhood. (Exhibit 4
and 5)

11. On the previous ICOSF website, there was also
a link to the Islamic Assembly of North America (IANA),
an organization that was shut down after an 11-count
indictment, issued by the U.S. Justice Department,
alleged that the group operated websites that "promoted
terrorism through suicide bombings and using airplanes
as weapons." (Exhibit 4
and 6)

12. In July of 2006, ICOSF brought Hatem Bazian to
speak to its congregation. Bazian was a former representative
for the Hamas charity, KindHearts, and in April of
2004, he was caught on videotape calling for an intifada
(armed uprising) against the United States. (Exhibit
7,
8
and 9)

13. Ayman Sokkarie, while he was Secretary of ICOSF
(1996-2001), stated, "Islam will be re-established
and the world will see how just Islam is and how false
all other ideologies are. It is just a matter of time."
(Exhibit 10
and 11)

14. Hassan Sabri is the imam of the Islamic Center
of South Florida (ICOSF).

15. Sabri grew up in Qalqilya of the "Palestinian
Territories" and came to the United States via
a "special travel document" issued by Israel
that expired roughly 20 years ago. (Exhibit
12)

16. In February and March of 2000, Sabri was a teacher
at the Islamic Center of Boca Raton (ICBR). (Exhibit
13)

17. During Sabri's time with ICBR, ICBR's website
had on it numerous links to www.qoqaz.net (Jihad in
Chechnya), one of the main websites raising funds
and recruiting fighters for Al-Qaeda and the Taliban
prior to 9/11. (Exhibit 14
and 15)

18. ICBR colleagues of Sabri's included: Bassem Alhalabi,
a colleage of Palestinian Islamic Jihad leader Sami
Al-Arian's, who was charged by the United States government
with illegally shipping military equipment to Syria;
Sayyed Khawer Ahmad, who was the webmaster for the
official website of Hamas's charitable and educational
apparatus, the Islamic Association (Al-Jamiya Al-Islamia);
Lamya Hashim, the former President of the now-defunct
Hamas-related charity, Health Resource Center for
Palestine; and Ibrahim Dremali, a radical imam, who
has admitted to being placed on the federal "no-fly"
list. (Exhibit 16
[word doc], 17,
18,
19
and 20)

19. In August of 2000, ICOSF placed on its website
a lecture Sabri had made to the congregation, entitled
'Kosova! What can we learn?' In it, he denounces the
United States as being the enemy of Islam. He states
the following: "Allah (SWT) tells us, in the
Quran, that the kuffar [non-Muslim/infidel] will continue
to fight Muslims - will continue to put a plan after
a plan and implement a plan after a plan - until Islam
will cease to be and until Muslims are either liquidated
or they have joined the Christian or the Jewish faith
And it is imperative upon us as Muslims belonging
to the Ummah of Islam to understand exactly what's
happening to our brothers, not only for the sake of
understanding alone, but so that we will know what
the enemies of Islam are planning, and so that we
will plan ourselves [The United States] is calling
its people and its army and its nation to rush to
the help of Muslims, but in reality this is not what's
going on. In reality what's going on is that they
want to mobilize Muslims and to use the vigor and
the vim that Muslims can generate - to use their money
and to use their souls and to use their lives - so
that they will further [the United States'] plans
in that part of the world [D]o not rely on the
kuffar, because if you do so, you will suffer."
(Exhibit
21)

20. In April of 2002, Sabri attended an anti-Israel
rally at Miami's Holocaust Memorial, where his group
made light of Nazi atrocities. (Exhibit
12)

21. In September of 2002, Sabri participated in an
event that included numerous Islamist radicals, including
Zulfiqar Ali Shah, the former South Asian director
of the Hamas charity, KindHearts. (Exhibit 22,
23
and 24)

22. On a radio show, at the start of 2003, Sabri stated
his belief that Jews have no right to Jerusalem and
that Allah should "rid Beit Al-Maqdis [Jerusalem]
of them sooner rather than later." As well, on
the show, he rationalized a statement in Islamic Hadith
- what he termed "a prophesy" - calling
on Muslims to murder Jews. (Exhibit
25)

23. On the same show, Sabri defended another imam's
(Ibrahim Dremali's) appearance as a character witness
at a hearing for Adham Hassoun, a fundraiser for terrorist
charities shut down by the United States government
for funneling millions of dollars to Hamas and Al-Qaeda.
(Exhibit 25
and 26)

24. CAIR or the Council on American-Islamic Relations
has acted as the voice of ICOSB, defending ICOSB in
the media against those that are against the building
of a new ICOSB mosque in the city of Pompano Beach.
(Exhibit
27)

25. CAIR was created, in June of 1994, by three leaders
from the Islamic Association for Palestine (IAP),
Nihad Awad, Omar Ahmad and Rafiq Jaber. (Exhibit
28 [pdf])

26. The IAP was the brainchild of Mousa Abu Marzook,
who resides in Damascus, Syria as the Deputy Political
Bureau Chief and the Spokesman of Hamas. (Exhibit
29
and 30)

27. In October of 1998, the former FBI Chief of Counter-Terrorism,
Oliver "Buck" Revell, stated, "IAP
is a Hamas front. It's controlled by Hamas, it brings
Hamas leaders to the U.S., it does propaganda for
Hamas." (Exhibit
31)

28. Hamas is on the U.S. State Department list of
Foreign Terrorist Organizations. (Exhibit
32)

29. The IAP was shut down, in 2005, after the group
was found liable for the murder of an American boy,
David Boim, who was killed during a Hamas attack in
Israel. (Exhibit
33)

30. In 1993, in Philadelphia, future leaders of CAIR
met to discuss ways in which they could raise money
within the United States for Hamas. (Exhibit
34)

31. One of the future CAIR leaders at the Philadelphia
meeting and the former Chairman of the IAP was Ghassan
Elashi. (Exhibit
34)

32. In January of 2006, Elashi was sentenced to seven
years in prison for financing Hamas. (Exhibit
35)

33. Nihad Awad, one of the founders of CAIR and current
National Executive Director of CAIR, was the Public
Relations Director for the IAP prior to CAIR being
created. (Exhibit
28 [pdf])

34. In March of 1994, Awad stated at Barry University
in Miami Shores, Florida, "After I researched
the situation inside and outside Palestine, I am in
support of the Hamas movement more than the PLO "
(Exhibit
36)

35. Omar Ahmad, one of the founders of CAIR and one
of the attendees at the Philadelphia meeting, was
the President of the IAP prior to CAIR being created.
(Exhibit 28 [pdf])

36. In July of 1998, as National Chairman of CAIR,
Ahmad stated at Flamingo Palace in Fremont, California,
"Islam isn't in America to be equal to any other
faith but to become dominant. The Koran, the Muslim
book of scripture, should be the highest authority
in America, and Islam the only accepted religion on
Earth." (Exhibit
37)

41. Al-Arian was the North American leader of Palestinian
Islamic Jihad (PIJ). (Exhibit
42)

42. PIJ is on the U.S. State Department list of Foreign
Terrorist Organizations. (Exhibit
32)

43. In May of 2006, Al-Arian was sentenced to 57 months
in prison for providing material support to PIJ. (Exhibit
43)

44. In February of 2007, CAIR, along with other Muslim
Brotherhood-related organizations, called for its
followers to fast in solidarity with Al-Arian, who
was, at the time, in the middle of a hunger strike.
(Exhibit
44)

45. In February of 2007, CAIR called on its followers
to write letters to government officials in support
of Al-Arian. (Exhibit
45)

46. In March of 2007, CAIR repeatedly called on its
followers to ask Attorney General Alberto Gonzalez
to free Al-Arian from prison. (Exhibit
46)

47. In September of 2003, during the Senate Judiciary
Subcommittee on Terrorism, Technology and Homeland
Security, Senator Charles Schumer (D-New York) stated
that CAIR leaders have "intimate links with Hamas"
and that CAIR has known "ties to terrorism."
(Exhibit
47)

48. In September of 2003, during the Senate Judiciary
Subcommittee on Terrorism, Technology and Homeland
Security, Senator Dick Durban (D-Illinois) stated
that CAIR is "unusual in its extreme rhetoric
and its associations with groups that are suspect."
(Exhibit
47)

49. In December of 2006, Senator Barbara Boxer rescinded
an award her office had given to the Executive Director
of CAIR-Sacramento, Basim Elkarra, in part for CAIR's
refusal to condemn Hamas and Hezbollah as terrorist
organizations. (Exhibit
48)

50. Starting in December of 2006, within the course
of 13 days, four CAIR leaders, including the National
Executive Director of CAIR, the National Communications
Director of CAIR, the National Legal Director of CAIR,
and the Executive Director of CAIR-Sacramento, refused
to condemn Hamas and Hezbollah as terrorist organizations.
(Exhibit 48,
49,
50
and 51)

51. In the Spring of 1998, the former FBI Chief of
Counter-Terrorism, Steve Pomerantz, stated, " CAIR,
its leaders, and its activities, effectively give
aid to international terrorist groups. Unfortunately,
CAIR is but one of a new generation of new groups
in the United States that hide under a veneer of 'civil
rights' or 'academic' status but in fact are tethered
to a platform that support terrorism. The degree to
which these groups are able to deceive the American
public and intimidate writers and counter-terrorist
officials will be a significant ingredient in whether
this country will be rendered more vulnerable to terrorism
in future years." (Exhibit
31)

52. It is my reasoned opinion that, based on the
facts in this case and my qualifications and expertise
in the field of terrorism, both the Islamic Center
of South Florida (ISCOF) and the Council on American-Islamic
Relations (CAIR) are working together to bring a
27,000 square foot mosque to the city of Pompano
Beach, Florida for no other reason than to spread
radical Islam throughout the area. This mosque,
if built, will indeed be a threat to the local neighborhood,
to South Florida, and to the United States in general.

_________________________________

(TYPE/PRINT NAME)

STATE OF _______________________

COUNTY OF _____________________

Subscribed and sworn to me this ______ day of ____________,
by ______________.

__________________________________

Signature of Notary Public-State of Florida

______________________________________________

(Print, type or stamp commissioned name of Notary
Public)

Personally known ________________ OR Produced identification________________